GLOBAL RESIDENCE AND CITIZENSHIP
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2 Contents 1 Residence and Citizenship 2 Residence Programs 3 4 Citizenship Programs Oneworld Group 2
3 Residence and Citizenship 3
4 Reasons Why Wealthy People Relocate (1) Security Safe alternative in times of political instability More privacy in investment and banking A defined legal environment is progressively sought after as more laws become increasingly vague Quality of life Better quality of life, climate, personal security Cleaner environment and lower air pollution Better offering of healthcare and transport systems 4
5 Why Wealthy People Relocate(2) Taxes Often the only way to reduce the tax burden and regulatory restrictions legally and in a significant manner is to relocate Education Graduation at a high ranking school and language skills are increasingly important as the basis for a successful career 5
6 Citizenship by Investment The term Citizenship by Investment describes the policies of countries in which foreign persons can obtain citizenship through capital investments or capital contributions in the country Several countries have programs in place to attract foreign investors in return for citizenship 6
7 Reasons for Alternative Citizenship (1) Visa waiver Opens travel to countries previously restricted by time consuming visa application processes Retirement The option to retire in a safe country Independence Be able to travel or have the option to relocate after possible political changes Mobility Freedom of movement when some nationals are overly exposed to terrorists threats and other hostility 7
8 Reasons for Alternative Citizenship (2) Protection Protection against data abuse, identity theft and cyber crime Tax Planning Citizenship can be relevant in tax planning and is one of the tie breaker rules in most double tax treaties Security Guarantees a secure and truly permanent alternative place to go if needed 8
9 Dual Citizenship Restrictions Half of the world s countries allow dual citizenship The acquisition of another citizenship can lead to the automatic loss of the current citizenship Carefully check the legal situation prior to taking any steps to acquire another citizenship 9
10 Residence Programs 10
11 Premier Residence Countries We set out the most attractive countries with regard to mobility, security, privacy, personal tax and lifestyle Australia Cyprus Monaco Switzerland Belgium Hong Kong Portugal UK Canada Malta Singapore US 11
12 Australia 12
13 Australia Introduction Population 23 mn Multi cultural society Liberal approach to immigration - it welcomes people to work and invest A good lifestyle is affordable 13
14 Australia - Significant Investor Visa The applicant has to invest AU$ 5 mn for a period of 4 years in a complying investment Investment can be government bonds, managed funds or private companies Applicants will need to meet standard health and character requirements They will need to lodge an expression of interest and be sponsored by a state or territory No minimum age limits No point test (so no minimum English requirement) Relaxed residence requirement (the investor has to spend only 160 days in Australia over 4 years) 14
15 Australia Permanent Residence Status Investors can extend their visa term by an additional 4 years bringing the maximum period on a Provisional Significant Investor Visa to 8 years After a minimum period of 4! years, the investor can apply for a Permanent Significant Investor visa 15
16 Australia Citizenship The applicant must: have been in Australia for 12 months as a permanent resident have had absences from Australia of no more than ¼ of the time in the previous 4 years be able to speak and understand basic English! Applicants must pass the Australian Citizenship Test, which focuses on Australia s values, history, and traditional and national symbols 16
17 Australia Taxation Progressive tax rates on income and capital gains of up to 54% (50% discount when capital assets have been held for at least 12 months) Australian tax residents are taxed on their worldwide income and capital gains no wealth tax no inheritance tax 17
18 Australia Summary Advantages Disadvantages Multi cultural society and a good place to live High taxes Excellent education system Low population density Acquisition of citizenship possible after 5 years 18
19 Belgium 19
20 Belgium Introduction Population 11 mn Hosts the headquarters of the EU and NATO Has a highly developed economy One of the world s largest trading nations 20
21 Belgium Resident Permit There are two main economic routes under which a person could qualify for residence: As a manager or highly skilled employee Minimum salary of (manager) or (highly skilled employee) - this entails a higher tax liability of 55% Processing time 2-3 months As a selfemployed individual The applicant incorporates his/her own company No minimum salary level - tax liability will be less Processing time 2-3 months The applicant is not restricted to remain only in Belgium but has the freedom to operate abroad 21
22 Belgium Citizenship The applicant must secure appropriate accommodation. It must be at his/her disposal at all times during the residence period in the country. After 5 years, it is possible to apply for citizenship The applicant must prove his/her social and economic integration After 10 years, the resident acquires the automatic right to become a Belgian citizen This is a unique feature that provides significant security 22
23 Belgium Taxation Progressive income tax of up to 50% (to be increased with local surcharges) No wealth tax In principle no capital gains tax on assets Commonly known as a high-tax jurisdiction, Belgium is in fact a discreet tax haven for affluent individuals and families who do not live off employment income Special tax rules for foreign employees temporarily residing in Belgium: The employee is treated as a non-resident and therefore is only taxed on Belgian source income 23
24 Belgium Summary Advantages Disadvantages Residence permit gives visa free access to all Schengen States Excellent infrastructure in the heart of Europe Attractive corporate and private taxation system Establishment of a company in Belgium is required in most cases Pre immigration tax planning required to take advantages of tax system Citizenship possible after 5 years of legal residence + 24
25 Canada 25
26 Canada Introduction Population 35 mn Regularly voted as one of the best countries to live in A good lifestyle is affordable Globally admired for its multi cultural society and tolerant foreign policies 26
27 Canada - Federal Immigrant Investor Program Created in 1986 Specific intention of attracting wealthy individuals with business experience Structured as a 5 year, zero interest loan to the Government Amount was increased to CAD and net wealth amount to CAD 1.6 mn. The new regulations did not see a decrease in the number of applicants Due to the exceptionally high volume of applications the program was closed in July 2011 The re-opening has not yet been confirmed as the Government is still considering various options for a major Federal IIP overhaul 27
28 Canada - Québec Immigrant Investor Program The program is very similar to the Federal Program The yearly maximum number of applications accepted is 1,750 The submission period for 2014 has ended An application can still be submitted if one has advanced intermediate knowledge of French 28
29 Cyprus 29
30 Cyprus Introduction Population Major hub for international trade and member of the EU Excellent quality of life with a year round climate of sunshine No tax in Cyprus for any income earned abroad 30
31 Cyprus - Global Residence Program Purchase real estate property with total cost min plus VAT Pay at least two thirds of the purchase cost prior to Application Stable means of annual income from abroad of at least per year Funds from abroad deposited in a bank in Cyprus in a 3-year fixed deposit account. The minimum deposit is
32 Cyprus - Advantages No minimum residence stay required Considered Non-Dom and any income received from abroad is exempt Residency can be granted in 2 months Applies to whole family Can lead to Cyprus citizenship Easier travel within the EU Lower tuition costs within Europe 32
33 Hong Kong 33
34 Hong Kong Introduction Population 7.2 mn Open economy with a free market and low taxation Liberal approach to immigration policy 34
35 Hong Kong - Capital Investment Program There are various categories for individuals to obtain residence in order to work, live or study Individuals who make a substantial investment to the economy are welcomed with open arms The Capital Investment Entrant Program requires an investment of no less than HK$10 mn (US$1.3 mn) into permissible investments of financial assets (including equities, debt securities, certificates of deposit or eligible collective investment schemes) for a period of 7 years 35
36 Hong Kong Timeframe Upon completion of 7 years ordinary residence, one may apply for Permanent Residence As a PR, one only needs to! return to Hong Kong once every 3 years to maintain status Program has been in place since people have received the visa (2.500 per year) 8 months processing time No residence requirement 36
37 Hong Kong Taxation An attractive Tax System: No capital gains tax No sales/value added tax No wealth/net worth tax No tax on inheritance or gifts No tax on interest income No withholding tax on dividends paid by Hong Kong companies Taxation is based on the territorial source principle, only levied on income sourced in Hong Kong There are three separate income rates: profit tax - flat rate of 15% on professional trade and business income property tax - flat rate of 15% (less standard deduction of 20%) salaries tax - levied on net chargeable income (either on progressive rate or flat rate) 37
38 Hong Kong Summary Advantages Disadvantages Straightforward Well established legal system Freest economy in the world World-class medical facilities and education institutions High property prices Poor air quality High population density Citizenship of limited interest 38
39 Portugal 39
40 Portugal Introduction Population 11 mn Lisbon, Oporto and Guimarães have been European Capitals of Culture The Algarve is a scenic treasure with a long coastline of golden beaches, dramatic cliffs 40
41 Portugal - Golden Residence Programme Programme came into force in October 2012 Allows non-eu nationals to be granted residence permits for certain investments. The options are: Acquisition of real estate of at least Transfer of capital of at least 1 mn Creation of of at least 10 new jobs Residence requirements for the 5 year programme: 7 days in the first year of residence, and 14 days for the two following two year renewals (1+2+2) 41
42 Portugal Permanent Residence Status After the 5 year programme, Permanent Residence (PR) status can be acquired The qualifying investment can be sold No residence requirement anymore, but! PR status can be revoked if holder is absent from Portugal for a period of 24 months, or is absent in aggregate of 30 months for a period of 3 years 42
43 Portugal Citizenship An application for citizenship can be made following a 6 year residence period! The application is subject to prevailing legal criteria, which currently includes a language test (European level A2) 43
44 Portugal Taxation A new, favorable tax treatment program for Non- Habitual Residents (NHRs) has been designed to attract talented individuals and HNWI's Progressive income tax of up to 48% Standard rate of VAT is 23% Income derived from a Portuguese source: flat rate of 20% (surcharges were announced recently) Income derived from a foreign source (relating to employment income, pension income and business and professional income) can be subject to exemption Granted for a period of 10 years. To be a tax resident, the individual has to remain in Portugal for 183 days and have a principal home which they intend to use as a habitual residence 44
45 Portugal Summary Advantages Disadvantages Straightforward and quick process Free travel within the Schengen Area Minimal physical presence requirements to secure renewal of residence permit Access to Permanent Residence requires basic understanding of the Portuguese language Requirements for citizenship applications (including language understanding) A country with lifestyle advantages - 45
46 Singapore 46
47 Singapore Introduction Population 5.3 mn One of the world s best places to live It is frequently voted best Asian city to live in One of the wealthiest and safest countries in the world 47
48 Singapore - Global Investor Programme The programme has been designed for investors who want to invest in Singapore and receive Permanent Residence To be eligible one: must possess at least 3 years of entrepreneurial track record, and have a company turnover at least SGD 50 mn per annum on average for the last 3 years (if in real estate or constructionrelated industry at least SGD 200 mn)! The Investor can choose one of the following options: Invest at least SGD 2.5 mn in a new business entity (one must submit a 3 year business plan; within 5 years, one must set up a business with 5 or more Singaporean employees and must incur at least SGD 1 mn in total business spending a year) Invest at least SGD 2.5 mn in a GIP fund that invests in Singaporebased companies 48
49 Singapore Citizenship Following the first 5 years, the PR will be renewed for another 5 years if the investor and his/her dependents have resided in Singapore for more than half of the time! An investor who is granted PR for 2 years is eligible to apply for Singapore citizenship Maximum of 1 year absence from Singapore out of the 2 years prior to the date of application Singapore does not allow dual citizenship 49
50 Singapore Taxation Singapore has a mild tax regime: Progressive personal income tax rate of up to 20% Standard corporate tax rate of 17% No capital gains tax (very limited exceptions) Taxation is based on the territorial source principle - only levied on income sourced in Singapore No gift taxes No income tax on dividends 50
51 Singapore Summary Advantages Disadvantages Safe and orderly with an excellent education system Favourable tax laws International financial center Acquisition of citizenship possible after 2 years of PR Property prices are relatively high Population density is very high Dual citizenship is not allowed It becomes difficult for foreign persons to get a work permit and renew the resident and PR status 51
52 United Kingdom 52
53 UK Introduction Population 63 mn One of the most attractive places in the world to live and do business International business environment - London is the financial capital of the world World renowned schools and universities Well connected with direct flight connections to almost all major cities in the world 53
54 UK - Immigrant Investor Program Part of the points based system, the Tier 1 Investor category is for high net worth individuals who want to make a financial investment in the UK Quick processing time of 4 to 8 weeks No requirement on English language for the first 5 years No health check required Investor Programs: GBP 10 mn or more may apply for PR after 2 years GBP 5 mn or more may apply for PR after 3 years GBP 1 mn or more may apply for PR after 5 years 54
55 UK Permanent Residence Status Conditions to apply for PR - also known as Indefinite Leave to Remain (ILR)! No more than 180 days spent outside the UK in any 12 month period (this only applies to the principal applicant) English language requirement All applicants must pass a simple 'Life in the UK' test (easy multiple choice) PR, once granted, has no expiry date PR will remain in force as long as the holder does not spend more than 2 years consecutively outside the UK 55
56 UK Citizenship Each applicant must maintain an average of 9 months or more per year in the UK for 5 years Unlike! PR, each individual is on their own time clock 56
57 UK Taxation Progressive income tax up to 45% Capital gains tax up to 28% No wealth tax Inheritance tax at 40% The obligation of personal UK taxes is based around the concepts of residence and domicile It is possible to be resident in the UK for tax purposes but non domiciled. This can provide many tax benefits 57
58 UK Summary Advantages Disadvantages London is among the financial capitals of the world World renowned schools Attractive tax system for wealthy individuals (resident, non-domiciled rules) Requirement for minimum physical presence Citizenship only after minimum 5 years of residence Straightforward investor immigration program with fast processing time 58
59 Citizenship Programs 59
60 Program Focus There are currently only six countries which offer citizenship programs that provide a direct, legal route to citizenship based on investment and sound due diligence Antigua St. Kitts && Barbuda Nevis Antigua Cyprus & Barbuda Malta Austria Dominica St. Kitts Malta & Nevis Other countries have similar provisions. However, in those countries there is no established or clear practice and/or the programs are not transparent 60
61 Antigua & Barbuda 61
62 Antigua and Barbuda Introduction Population 80,000 Some of the most beautiful beaches in the world Visa free travel to 129 countries Tourism generates around 60% of the island s income 62
63 Antigua and Barbuda Citizenship Investment Program Announced in November 2012 To qualify for citizenship, the Government requires either: A contribution to the National Development Fund of US$ (usually US$ ) for a single applicant An investment in an approved real estate project with a value of at least US$ An investment into a business, known as the Direct Investment route Additional Due Diligence fees of US$ and Government fees of US$ apply (for up to 4 people) 63
64 Cyprus 64
65 Cyprus Introduction Population Major hub for international trade and member of the EU Excellent quality of life with a year round climate of sunshine Tax burden is low 65
66 Cyprus Citizenship Investment Program (1) An express procedure, it takes only 3 months to be approved The investment is as low as 2.5 mn Citizenship granted to spouse and minor children No requirement to reside in Cyprus Visa free travel to over 150 countries 66
67 Cyprus Citizenship Investment Program (2) There are two schemes available to qualify for Citizenship by Investment: Individual scheme with threshold of 5 mn Collective Scheme with threshold of 2.5 mn Individual Scheme with threshold of 5 mn Collective Scheme with threshold of 2,5 mn Investment min 5 mn in Cyprus government bonds, or Investment min 5 mn in financial instruments of companies and shares,or Investment min 5 mn in real estate, or Investment min 5 mn in Cyprus businesses/companies, or Deposit in Cyprus banks amount to 5 mn Reduced amount of 2.5 mn on the basis that they participate in a collective investment scheme with a total value min 12.5 mn: Investment in government bonds, or Investment in financial instruments, or Investment in real estate and land developing, or Investment in Cyprus businesses and companies 67
68 Malta 68
69 Malta Introduction Population Among the earliest settlements in the world, years of history EU member since 2004, member of the Schengen area since 2007 Visa free travel to more than 160 countries Citizenship gives right of work and establishment in all 28 EU countries 69
70 Malta - Citizenship Investment Program Contribution to the National Economic and Social Development Fund A residence in Malta for at least 5 years Investments into approved financial instruments For main applicant For spouse For dependents under / over 18 years / each Purchase of a property: value over , OR Leasing of a property: annual rent over For at least 5 year Annual publication of all naturalised citizens Due Diligence fees for main applicant for spouse for dependents under / over 18 years: / each 70
71 St. Kitts & Nevis 71
72 Population 54,000 Unrivalled natural beauty Visa free travel to 131 countries Direct daily flights from Miami and by weekly direct flights from New York and London 72
73 St Kitts and Nevis Citizenship Investment Program It remains the world s most successful program To qualify for citizenship, applicants have two investment options: A contribution to the Sugar Industry Diversification Foundation of US$ (for a single applicant) An investment in designated real estate with a value of at least US$ Additional Due Diligence fees of US$7.500 and Government fees of US$ apply for the real estate option 73
74 St. Kitts & Nevis Vs. Antigua & Barbuda Similar citizenship and residence privileges, although important differences: Processing time Residence requirement Applicant to swear an oath of allegiance Access to countries visa free Established program which usually takes 6-8 months for approvals to be granted No No St. Kitts & Nevis 131 countries - visa free travel to Tonga, Israel, Bangladesh and Argentina (Antigua & Barbuda does not) Antigua & Barbuda New program so will potentially be processed more quickly Requires the applicant to spend an average of a week per year (35 days over 5 years) over the length of the program Yes, either on the island or at an embassy or consulate around the world 129 countries - visa free travel to Ukraine and South Africa (St. Kitts and Nevis does not) 74
75 Oneworld Group 75
76 Citizenship and Residency Residence planning and related tax planning for private clients involves finding solutions for individuals and families who move internationally, own property in different countries and who often have complex international situations and requirements For many individuals the option of a second or even third citizenship is very attractive. The freedom which is granted to them is unparalleled Our citizenship and residence advisory for private clients involves fiduciary solutions for individuals and families who move internationally, possibly own property in different countries and who often have international situations and requirements 76
77 Enquiries You can direct your enquires concerning Private Client Services to: Oneworld ltd 75 Prodromou Avenue Savvas Shiatis Oneworld House Nicosia, Cyprus Theodoros Theodorou Oneworld MidEast ltd Bayswater Tower, floor 18 Al Abraj South Street Business Bay Dubai, UAE Costas Ioannou Alexandros Philippides or contact our chairman George Philippides 77
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